This comment form is no longer interactive because the comment period is closed.

Technical Rationale for Reliability Standards (Second Posting)

Description:

Start Date: 03/05/2020
End Date: 04/20/2020

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
Technical Rationale for Reliability Standards BAL-005-1 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards BAL-005-1 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards EOP-008-2 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards EOP-008-2 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards NUC-001-3 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards NUC-001-3 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards TOP-002-4 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards TOP-002-4 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards TOP-003-3 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards TOP-003-3 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards TOP-010-1(i) Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards TOP-010-1(i) Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards PRC-005-6 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards PRC-005-6 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards PRC-006-3 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards PRC-006-3 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards PRC-006-SERC-02 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards PRC-006-SERC-02 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020
Technical Rationale for Reliability Standards VAR-501-WECC-3.1 Non-Binding Poll IN 1 NB Technical Rationale for Reliability Standards VAR-501-WECC-3.1 Non-Binding Poll 03/05/2020 04/03/2020 04/10/2020 04/20/2020

Filter:

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

Consider defining acronyms upon first use since this will be a stand-alone document.

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

N/A

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

No Comments.

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

Oklahoma Gas & Electric supports Edison Electric Institute's (EEI) response.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

Duke Energy agrees with Recommendation provided the:

(1)   Reliability Standard revision number does not change (minimizes administrative burden),

(2)   Removed Guideline/Technical Basis/Rationale information is placed on the NERC Website in its entirety under the Reliability Standards “Related Information” section (readily provides information access), and

(3)   NERC Standing Committee concedes ownership of the removed Guideline/Technical Basis/Rationale information and mandates that present and future NERC Standards Drafting Team(s) dutifully update and revise this information to keep its content up-to-date (ensures information is available and current).

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

The GTB sections within the Standards provide background information and context for the Requirements and Measures, often helping interpret what is found in the Standards. Removal of this section results in less structure with interpretation of the Standards. Tacoma Power would prefer that the GTB section remain in the Standard, but if the GTB section is to be ultimately transitioned to a separate Technical Rationale document, it is requested that hyperlink references be provided within the Standard and the applicable Technical Rationale documents in order to maintain continuity.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Texas RE recommends reviewing the following sentence (or similar sentences) in all Technical Rationale documents:  “Upon BOT approval, the text from the rationale text boxes was moved to this section.” This is not exactly a true statement anymore.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from BAL-005-1, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Ballot and Commenting events, no less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also supports comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

Evergy (Westar Energy) incorporates by reference and supports the response of Edison Electric Institute and the response of MRO NERC Standards Review Forum (MRO NSRF).

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

Please consider revising the standard page numbering since the standard will have fewer pages. Please consider revising the Technical Rationale page numbering (Example: 1 of X number of pages.)

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from BAL-005-1, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

N/A - No opinion.

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB and Rationale should be kept in their current format within each standard. Reclamation recommends that the content of GTB and Rationale can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation acknowledges that BAL-005-1 does not have a GTB, but asserts the Rationale provides useful information. In this situation, Reclamation recommends the Supplemental Material section be retained.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Ballot and Commenting events, no less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less.  The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Minnesota Power agrees that the use of the term “guideline” in the GTB section can create confusion while developing compliance approaches. If the intent of this section is to explain the technical basis for the Standard and provide technical guidance and not to provide compliance examples or compliance language, then separating it from the Standard will address this.  Creating separate documents for Technical Rationale and Implementation Guidance will be helpful to further clarify the distinction between the two. 

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

Non-substantive suggestion to add quotation marks after the word “communications” so that the sentence reads:  “Rationale for Requirement R1: The phrase "data exchange capabilities" is replacing “data communications in Requirement R1, Part 1.2.2 for the following reasons:”

Also, this sentence may need to be rephrased to indicate that the rationale is a separate document from the Reliability Standard:  “The rationale included in the IRO-002-4 standard discusses the need to retain the topic of data exchange, as it is not addressed in the COM standards.”

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

N/A

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

No Comments.

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

Oklahoma Gas & Electric supports Edison Electric Institute's (EEI) response.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

The GTB sections within the Standards provide background information and context for the Requirements and Measures, often helping interpret what is found in the Standards. Removal of this section results in less structure with interpretation of the Standards. Tacoma Power would prefer that the GTB section remain in the Standard, but if the GTB section is to be ultimately transitioned to a separate Technical Rationale document, it is requested that hyperlink references be provided within the Standard and the applicable Technical Rationale documents in order to maintain continuity.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

A direct link to the rationale information placed in the standard would make the information much easier to access.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from EOP-008-2, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

 

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

LDWP agrees with the recommendation, but only if the Standard number changes; even if this is EOP-008-2(i), a naming convention that NERC has used in the past. The Standard may be functionally the same, but it is still different. LDWP does not believe that there should be deviation from this convention.

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

Evergy (Westar Energy) incorporates by reference and supports the response of Edison Electric Institute and the response of MRO NERC Standards Review Forum (MRO NSRF).

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

Please consider revising the standard page numbering since the standard will have fewer pages. Please consider revising the Technical Rationale page numbering (Example: 1 of X number of pages.)

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from EOP-008-2, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB and Rationale should be kept in their current format within each standard. Reclamation recommends that the content of GTB and Rationale can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation acknowledges that EOP-008-2 does not have a GTB and asserts the Rationale appears to be more of a version history containing a list of errata changes or other information that should properly be contained in the “Background” section of the standard. In this situation, Reclamation recommends the irrelevant parts of the existing Rationale be deleted or the pertinent parts moved to the Background section of the standard.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Minnesota Power agrees that the use of the term “guideline” in the GTB section can create confusion while developing compliance approaches. If the intent of this section is to explain the technical basis for the Standard and provide technical guidance and not to provide compliance examples or compliance language, then separating it from the Standard will address this.  Creating separate documents for Technical Rationale and Implementation Guidance will be helpful to further clarify the distinction between the two. 

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

Consider defining acronyms upon first use since this will be a stand-alone document.

If the NUC FYRT recommendations were implemented in the Reliability Standard, then the recommendations do not need to be repeated in the Technical Rationale.  If the rationale on why the recommendations were implemented was added or elaborated upon, then that would be appropriate for the Technical Rationale.

Project 2010-05.2 has been implemented; this sentence should be rephrased:  “Project 2010-05.2 has proposed to replace SPS with RAS throughout all of the NERC Standards in order to move to the use of a single term.”

Background Section 5 should  be moved to the Technical Rationale. It explains the formation of the “NUC FYRT” and the dates the recommendations were accepted.  This is not essential standards information but is more useful in understanding the reference cases in the Technical Rationale that have been moved out of the standard.

Furthermore, if NERC is creating a “reliability standard template” that would apply to the entire suite of Reliability Standards, the IRC suggests that the “Background” section be standardized, perhaps including a link the Project Page for that standard or references to an applicable FERC docket.  However, not all of the Reliability Standards include a “Background” section, so another alternative would be to remove the Background section and include the discussion there in the Technical Rationale document. 

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

N/A

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

No Comments.

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

Oklahoma Gas & Electric supports Edison Electric Institute's (EEI) response.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from NUC-001-3, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

Evergy (Westar Energy) incorporates by reference and supports the response of Edison Electric Institute and the response of MRO NERC Standards Review Forum (MRO NSRF).

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

Please consider revising the standard page numbering since the standard will have fewer pages. Please consider revising the Technical Rationale page numbering (Example: 1 of X number of pages.)

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from NUC-001-3, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

N/A - No opinion.

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB and Rationale should be kept in their current format within each standard. Reclamation recommends that the content of GTB and Rationale can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation acknowledges that NUC-001-3 does not have a GTB and asserts the Rationale appears to be more of a version history containing a list of errata changes or other information that should properly be contained in the “Background” section of the standard.  In this situation, Reclamation recommends the irrelevant parts of the existing Rationale be deleted or the pertinent parts moved to the Background section of the standard.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Not applicable to Minnesota Power. 

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

TOP-001-4 is the currently effective version, so this sentence can be rephrased:  “The change to Requirement R2 is in response to NOPR paragraph 42 and in concert with proposed changes made to proposed TOP-001-4.”

For the changes made in response to IERP recommendation, it would be helpful to have the reason why the recommendation was made in the Technical Rationale document than just the statement on who made the recommendation.

In addition, since the technical rationale is a separate document it would be beneficial to provide a link to the NOPR or the docket number that would make it easier for the reader to look more closely at the NOPR if desired.

Recommend defining acronyms upon first use since this will be a stand-alone document.

Recommend adding what the SW Outage Report Recommendation was and why it was made rather than just referring to it as the reason for the change and providing no explanation as to the reason.

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

N/A

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

No Comments.

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

Oklahoma Gas & Electric supports Edison Electric Institute's (EEI) response.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

The GTB sections within the Standards provide background information and context for the Requirements and Measures, often helping interpret what is found in the Standards. Removal of this section results in less structure with interpretation of the Standards. Tacoma Power would prefer that the GTB section remain in the Standard, but if the GTB section is to be ultimately transitioned to a separate Technical Rationale document, it is requested that hyperlink references be provided within the Standard and the applicable Technical Rationale documents in order to maintain continuity.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from TOP-002-4, however, we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

Evergy (Westar Energy) incorporates by reference and supports the response of Edison Electric Institute and the response of MRO NERC Standards Review Forum (MRO NSRF).

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

Please consider revising the standard page numbering since the standard will have fewer pages. Please consider revising the Technical Rationale page numbering (Example: 1 of X number of pages.)

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from TOP-002-4, however, we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

In addition to the above information, EEI ask NERC to reference the NOPR cited in this TR.  While it is currently identified within the revision history of the associated Reliability Standard, the TR is now a stand-alone document and should contain a reference to any document prominently cited within the TR.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB and Rationale should be kept in their current format within each standard. Reclamation recommends that the content of GTB and Rationale can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation asserts that TOP-002-4 GTB and Rationale do not provide useful information except for the rationale related to definitions. In this situation, Reclamation recommends the irrelevant parts of the existing GTB and Rationale be deleted or the pertinent parts moved to the Background section of the standard.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

References to “proposed” should be removed now that the version is effective.

Recommend defining acronyms upon first use since this will be a stand-alone document.

Recommend providing detail regarding the NOPR referenced in the Technical Rationale such as the Docket Number and a brief description as to the recommendations from the NOPR paragraphs that were cited.

Recommend adding the SW Outage Report recommendation 27 text so the Technical Rationale can be a stand-alone document.  A link to where to obtain the document should also be included in the Technical Rationale.

 

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

No Comments.

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

Oklahoma Gas & Electric supports Edison Electric Institute's (EEI) response.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

The GTB sections within the Standards provide background information and context for the Requirements and Measures, often helping interpret what is found in the Standards. Removal of this section results in less structure with interpretation of the Standards. Tacoma Power would prefer that the GTB section remain in the Standard, but if the GTB section is to be ultimately transitioned to a separate Technical Rationale document, it is requested that hyperlink references be provided within the Standard and the applicable Technical Rationale documents in order to maintain continuity.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from TOP-003-3, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

Evergy (Westar Energy) incorporates by reference and supports the response of Edison Electric Institute and the response of MRO NERC Standards Review Forum (MRO NSRF).

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

Please consider revising the standard page numbering since the standard will have fewer pages. Please consider revising the Technical Rationale page numbering (Example: 1 of X number of pages.)

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from TOP-003-3, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

In addition to the above information, EEI ask NERC to reference the NOPR cited in this TR.  While it is currently identified within the revision history of the associated Reliability Standard, the TR is now a stand-alone document and should contain a reference to any document prominently cited within the TR.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB should be kept in their current format within each standard. Reclamation recommends that the content of GTB can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation asserts that TOP-003-3 GTB and Rationale do not provide useful information except for the rationale related to definitions. In this situation, Reclamation recommends the irrelevant parts of the existing GTB and Rationale be deleted or the pertinent parts moved to the Background section of the standard.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Minnesota Power agrees that the use of the term “guideline” in the GTB section can create confusion while developing compliance approaches. If the intent of this section is to explain the technical basis for the Standard and provide technical guidance and not to provide compliance examples or compliance language, then separating it from the Standard will address this.  Creating separate documents for Technical Rationale and Implementation Guidance will be helpful to further clarify the distinction between the two. 

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

This is an instance where confusion may be created on the use of the information in the GTB section since it may be used by entities to develop compliance approaches to meet the requirements. 

Consideration should be given if the information in the GTB section can be incorporated in the existing Compliance Implementation Guidance Real-time Assessment Quality of Analysis where the purpose of this guidance document is to assist NERC registered entities in establishing a common understanding of the practices and processes surrounding the quality of analysis used in completion of a Real-time Assessment as applied in NERC Standard TOP-010-1(i).

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

N/A

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

This is an instance where confusion may be created on the use of the information in the GTB section since it may be used by entities to develop compliance approaches to meet the requirements.

Consideration should be given if the information in the GTB section can be incorportated in the existing Compliance Implementation Guidance Real-time Assessment Quality of Analysis where the purpose of this guidance document is to assist NERC registered entities in establishing a common understanding of the practices and processes surrounding the quality of analysis used in completion of a Real-time Assessment as applied in NERC Standard TOP-010-1(i).

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

Oklahoma Gas & Electric supports Edison Electric Institute's (EEI) response.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

The GTB sections within the Standards provide background information and context for the Requirements and Measures, often helping interpret what is found in the Standards. Removal of this section results in less structure with interpretation of the Standards. Tacoma Power would prefer that the GTB section remain in the Standard, but if the GTB section is to be ultimately transitioned to a separate Technical Rationale document, it is requested that hyperlink references be provided within the Standard and the applicable Technical Rationale documents in order to maintain continuity.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Texas RE noticed the Guidelines and Technical Basis provide examples of how to comply with the standard and should be considered for Implementation Guidance.  For example, in the following excerpt, only the first sentence is rationale.  The bold portion reads like implementation guidance: “Requirement R3 ensures TOPs have procedures to address issues related to the quality of the analysis results used for Real-time Assessments. Requirements to perform Real-time Assessments appear in other Reliability Standards. Examples of the types of analysis used in Real-time Assessments may include, as applicable, state estimation, Real-time Contingency analysis, Stability analysis or other studies used for Real-time Assessments. Examples of the types of criteria used to evaluate the quality of analysis used in Real-time Assessments may include solution tolerances, mismatches with Real-time data, convergences, etc. The Operating Process or Operating Procedure must describe how the quality of analysis results used in Real-time Assessment will be shown to operating personnel.” 

 

Another example is in Requirement R4.  The following statements are implementation guidance: “ An alarm process monitor could be an application within a Real-time monitoring system or it could be a separate system. 'Heartbeat' or 'watchdog' monitors are examples of an alarm process monitor. An alarm process monitor should be designed and implemented such that a stall of the Real-time monitoring alarm processor does not cause a failure of the alarm process monitor.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from TOP-010-1(i), however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

 

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

Evergy (Westar Energy) incorporates by reference and supports the response of Edison Electric Institute and the response of MRO NERC Standards Review Forum (MRO NSRF).

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

Please consider revising the standard page numbering since the standard will have fewer pages. Please consider revising the Technical Rationale page numbering (Example: 1 of X number of pages.)

This is an instance where confusion may be created on the use of the information in the GTB section since it may be used by entities to develop compliance approaches to meet the requirements.

 

Because there is existing compliance implementation guidance for Real-time Assessment Quality of Analysis(link), consideration should be given toincorportating the material in the standard to  the existing guidance document to to enable NERC registered entities in establishing a common understanding of the practices and processes surrounding the quality of Real-time Assessment analysis expected to be used  for meeting NERC Standard TOP-010-1(i).

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from TOP-010-1(i), however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB should be kept in their current format within each standard. Reclamation recommends that the content of GTB can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation asserts that TOP-010-1(i) GTB and Rationale provide useful information. In this situation, Reclamation recommends the Supplemental Material section be retained.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Minnesota Power agrees that the use of the term “guideline” in the GTB section can create confusion while developing compliance approaches. If the intent of this section is to explain the technical basis for the Standard and provide technical guidance and not to provide compliance examples or compliance language, then separating it from the Standard will address this.  Creating separate documents for Technical Rationale and Implementation Guidance will be helpful to further clarify the distinction between the two. 

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

Recommend adding to the Rationale for Revisions for Component Type the reason for adding additional elements to the definition of “Automatic Reclosing” rather than stating only that the elements increased.

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

No Comments.

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

Oklahoma Gas & Electric supports Edison Electric Institute's (EEI) response.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

The GTB sections within the Standards provide background information and context for the Requirements and Measures, often helping interpret what is found in the Standards. Removal of this section results in less structure with interpretation of the Standards. Tacoma Power would prefer that the GTB section remain in the Standard, but if the GTB section is to be ultimately transitioned to a separate Technical Rationale document, it is requested that hyperlink references be provided within the Standard and the applicable Technical Rationale documents in order to maintain continuity.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from PRC-005-6, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

Evergy (Westar Energy) incorporates by reference and supports the response of Edison Electric Institute and the response of MRO NERC Standards Review Forum (MRO NSRF).

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

Please consider revising the standard page numbering since the standard will have fewer pages. Please consider revising the Technical Rationale page numbering (Example: 1 of X number of pages.)

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from PRC-005-6, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB and Rationale should be kept in their current format within each standard. Reclamation recommends that the content of GTB and Rationale can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation acknowledges that PRC-005-6 does not have a GTB and asserts the Rationale appears to be more of a version history containing a list of errata changes or other information that should properly be contained in the “Background” section of the standard. In this situation, Reclamation recommends the irrelevant parts of the existing Rationale be deleted or the pertinent parts moved to the Background section of the standard.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

N/A

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

No Comments.

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

Oklahoma Gas & Electric supports Edison Electric Institute's (EEI) response.

 

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

The GTB sections within the Standards provide background information and context for the Requirements and Measures, often helping interpret what is found in the Standards. Removal of this section results in less structure with interpretation of the Standards. Tacoma Power would prefer that the GTB section remain in the Standard, but if the GTB section is to be ultimately transitioned to a separate Technical Rationale document, it is requested that hyperlink references be provided within the Standard and the applicable Technical Rationale documents in order to maintain continuity.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from PRC-006-3, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

Evergy (Westar Energy) incorporates by reference and supports the response of Edison Electric Institute and the response of MRO NERC Standards Review Forum (MRO NSRF).

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

Please consider revising the standard page numbering since the standard will have fewer pages. Please consider revising the Technical Rationale page numbering (Example: 1 of X number of pages.)

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from PRC-006-3, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB and Rationale should be kept in their current format within each standard. Reclamation recommends that the content of GTB and Rationale can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation acknowledges that PRC-006-3 does not have a GTB and asserts the Rationale appears to be more of a version history containing a list of errata changes or other information that should properly be contained in the “Background” section of the standard. In this situation, Reclamation recommends the irrelevant parts of the existing Rationale be deleted or the pertinent parts moved to the Background section of the standard.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

This is an example where the Basis section (first 2 pages) could be moved to an Implementation Guidance document rather than remain in the Technical Rationale document.

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

N/A

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

N/A

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

These comments represent the MRO NSRF membership as a whole but would not preclude members from submitting individual comments”.  Though,  this is not applicable to MRO members, we agree with removing the GTB in order to be consistant wth the continent wides Standards format.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI disagrees with removing the following statement currently contained in the Guideline and Technical Basis of the SERC Regional Reliability Standard:

Basis for SERC standard requirements

SERC Standard PRC-006-SERC-02 is not a stand-alone standard, but was written to be followed in conjunction with NERC Standard PRC-006-1. The primary focus of SERC Standard PRC-006-SERC-02 was to provide region-specific requirements for the implementation of the higher tier NERC standard requirements with the goals of a) adding clarity and b) providing for consistency and a coordinated UFLS scheme for the SERC Region as a whole. Generally speaking, requirements already in the NERC standard were not repeated in the SERC standard. Therefore, both the NERC and SERC standards must be followed to ensure full compliance.

EEI is of the opinion that this statement should be retained within PRC-006-SERC-02 given that this standard is not a “stand-alone” Reliability Standard. 

Should this inadvertent, but important statement be included within the Technical Rationale (TR), EEI will also support the removal of the Technical Rationale (TR) from PRC-006-SERC-02, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

 

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

No Position. Not in ballot pool.

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI disagrees with removing the following statement currently contained in the Guideline and Technical Basis of the SERC Regional Reliability Standard:

Basis for SERC standard requirements

SERC Standard PRC-006-SERC-02 is not a stand-alone standard, but was written to be followed in conjunction with NERC Standard PRC-006-1. The primary focus of SERC Standard PRC-006-SERC-02 was to provide region-specific requirements for the implementation of the higher tier NERC standard requirements with the goals of a) adding clarity and b) providing for consistency and a coordinated UFLS scheme for the SERC Region as a whole. Generally speaking, requirements already in the NERC standard were not repeated in the SERC standard. Therefore, both the NERC and SERC standards must be followed to ensure full compliance.

EEI is of the opinion that this statement should be retained within PRC-006-SERC-02 given that this standard is not a “stand-alone” Reliability Standard. 

Should this inadvertent, but important statement be included within the Technical Rationale (TR), EEI will also support the removal of the Technical Rationale (TR) from PRC-006-SERC-02, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

N/A - No opinion.

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB and Rationale should be kept in their current format within each standard. Reclamation recommends that the content of GTB and Rationale can be revised to provide experience gained (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation asserts that PRC-006-SERC-02 GTB and Rationale provide useful information. In this situation, Reclamation recommends the GTB and Rationale sections be retained.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Not applicable to Minnesota Power. 

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0

Hot Answers

California ISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 4/20/2020

- 0 - 0

SRC 2020, Segment(s) 2, 1, 3, 12/18/2019

- 0 - 0

Other Answers

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 3/23/2020

- 0 - 0

N/A

Carl Pineault, Hydro-Qu?bec Production, 5, 3/23/2020

- 0 - 0

Judianne O'Brien, On Behalf of: Michael Puscas, ISO New England, Inc., 2

- 0 - 0

Leonard Kula, Independent Electricity System Operator, 2, 3/31/2020

- 0 - 0

Michelle Amarantos, 4/7/2020

- 0 - 0

Laura Nelson, On Behalf of: IDACORP - Idaho Power Company, , Segments 1

- 0 - 0

N/A

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tri-State prefers the Guidance and Technical Basis (GTB) continue to be included in the same process as standards development. Specifically, we would like to see the GTB continue to be developed at the same time as the standard, and posted for comment at the same time as the standard. Without these documents combined, what assurance does industry have that they will be developed in tandem and posted for industry comment in tandem? The primary reason is to allow entities to comment on the GTB during the drafting of the standard. For example, the Virtualization project has extensive Technical Rationale which Tri-State has used as a basis for understanding the changes and for making comments on the standards under development.

Kjersti Drott, Tri-State G and T Association, Inc., 1, 4/13/2020

- 0 - 0

Salt River Project (SRP) sees this as an administrative task that does not add to the reliability of the Bulk Electric System.  Separating out the Guidelines and technical rational into separate documents would require the tracking of these documents for updates.  SRP also has process documentation that references the GTB sections of the standard that would need to be updated to reference the new documents. SRP also likes the GTB within the standards so they may be reviewed when there is a revision to the standard.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

These comments represent the MRO NSRF membership as a whole but would not preclude members from submitting individual comments”.  Though,  this is not applicable to MRO members, we agree with removing the GTB in order to be consistent with the continent wides Standards format.

 

The NSRF would also like to make two additional general comments.  1.  We recommend that NERC add this to the Standard’s “one-stop shopping” spreadsheet.  And 2, this process should also be applied to “Background” information such as in the CIP Standards.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

- 0 - 0

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

See Question #1 Comments.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

- 0 - 0

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 4/17/2020

- 0 - 0

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 4/17/2020

- 0 - 0

The GTB sections within the Standards provide background information and context for the Requirements and Measures, often helping interpret what is found in the Standards. Removal of this section results in less structure with interpretation of the Standards. Tacoma Power would prefer that the GTB section remain in the Standard, but if the GTB section is to be ultimately transitioned to a separate Technical Rationale document, it is requested that hyperlink references be provided within the Standard and the applicable Technical Rationale documents in order to maintain continuity.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Please see comments submitted by Edison Electric Institute.

Neil Shockey, Edison International - Southern California Edison Company, 5, 4/17/2020

- 0 - 0

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/20/2020

- 0 - 0

Christopher Searles, On Behalf of: Small User, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Exelon concurs with the comments submitted by EEI.

Submitted on behalf of Exelon for Segments 1, 3, 5, and 6.

Daniel Gacek, Exelon, 1, 4/20/2020

- 0 - 0

Ameren agrees with and supports EEI comments.

David Jendras, Ameren - Ameren Services, 3, 4/20/2020

- 0 - 0

EEI supports the removal of the Technical Rationale (TR) from VAR-501-WECC-3.1, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•            Project Number under which the Technical Rationale was originally developed

•            Date the Technical Rational was originally developed

 

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

We prefer to have the rational retained with the standard. We refer to it for help to explain the meaning and intent of the current standard. Keeping the related information with the standard saves additional searching for the information.

Jeanne Kurzynowski, On Behalf of: Consumers Energy Company - RF - Segments 1, 3, 4, 5

- 0 - 0

NV Energy supports and agrees with EEI's comments on the removal of the Technical Rationale from BAL-005-1, and disagreement with the manner and method this is being done. For these reasons, we ask NERC to add the following information to provide needed context in the new Technical Rationale document to ensure proper linkage between the Standard and this new document: 

•          Project Number under which the Technical Rationale was developed

•          Date the Technical Rational was originally developed

•          Hyperlink to the Project Page

•          Date the Reliability Standard was approved

•          Hyperlink to the Standard

Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

- 0 - 0

The entire Technical Rationale for Reliability Standards Project is an inefficient and unnecessary administrative task that undermines the value of the Industry vetted and FERC approved Reliability Standards.

This project adds zero value to the reliability of the BES, at what expense? This project creates more confusion, not less; more paperwork, not less; several more Balloting and Commenting events, not less; consumes more staff time, money and resources for NERC, Regional Entities, and Registered Entities, not less. 

The end product, after the estimated five or more years this project will take, will be yet more NERC documents for each Reliability Standard and zero Reliability improvement to the BES.

NCPA also support comments by Salt-River Project, Tacoma Power, and Tri-State related to this second posting of the subject project.

Marty Hostler, Northern California Power Agency, 5, 4/20/2020

- 0 - 0

Glenn Barry, Los Angeles Department of Water and Power, 5, 4/20/2020

- 0 - 0

See Response to Question 1

Michael Whitney, Northern California Power Agency, 3, 4/20/2020

- 0 - 0

No Position. Not in ballot pool.

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

- 0 - 0

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 5, 7, 3, 1, 6, 4/20/2020

- 0 - 0

As stated by EEI:

EEI supports the removal of the Technical Rationale (TR) from VAR-501-WECC-3.1, however we suggest certain additional information be included in the TR to demonstrate a stronger and clearer association between the Reliability Standard and the TR document.  Registered entities would benefit from the inclusion of the following information, which will provide historical context and allow easier access to the relevant related documents:

•          Project Number under which the Technical Rationale was originally developed

•          Date the Technical Rational was originally developed

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

N/A - No opinion.

Teresa Cantwell, Lower Colorado River Authority, 5, 4/20/2020

- 0 - 0

In general, Reclamation recommends GTB and Rationale should be kept in their current format within each standard. Reclamation recommends that the content of GTB and Rationale can be revised to provide gained experience (similar to lessons learned) from implementing and using the standards. Technical basis can be beneficial for implementing and understanding the requirements of the standards. All documentation and guidance pertaining to each standard should be contained in the same document as the standard to facilitate ease of reference.

Reclamation asserts that VAR-501-WECC-3.1 GTB provides useful information. In this situation, Reclamation recommends the GTB section be retained.

Reclamation recommends standards should not be revised simply for the sake of revising the format. Standards should be revised only when the content needs to be updated. Any changes to format should be incorporated at the time of content revisions. If GTB and Rationale must be removed from their standards, Reclamation recommends NERC publish GTB and Rationale in a “book” type aggregation to facilitate ease of locating the information.

Richard Jackson, U.S. Bureau of Reclamation, 1, 4/20/2020

- 0 - 0

Please see Response to Question 1

Dennis Sismaet, Northern California Power Agency, 6, 4/20/2020

- 0 - 0

Not applicable to Minnesota Power. 

Jamie Monette, Allete - Minnesota Power, Inc., 1, 4/20/2020

- 0 - 0